COMMONWEALTH of V1RQINIA ORIGINAL (Red) eonon STATE ^^ER CONTROL BOARD Exwutlw bimctor Vattey Regional Office BOARD MEMBERS iJ6 North Main Street Patrick L-Sundlofl Post Offtet Box 11143 P.O. Box S68 . Virgin*228/2 (703)828-2595 W»'wd B. Riei.4r. - i , rtoc Witkliw M, Abbltt. Jr. 4 January 1985 '/ '/ . Jowh8.c™g«^j Robert C.WJninfler H»nry 0. Hollimon Ms. Susan Insetta (3HW14) CERCLA Enforcement Environmental Protection Agency 6th & Walnut Streets Philadelphia, PA 19106 RE: Avtex Fibers, Inc., Front Royat, VA Dear Ms. Insetta: ;/ ; As recently discussed with you, Avtex Fibers, Inc., Front Royal, Virginia has requested the Office of Emergency and Remedial Response to have their Hazardous Ranking System score revlied (see enclosures). As you are aware, Avtex Is conducting a comprehensive study of the ground water pollution at this site at the request of the Virginia State Water Control Board (SWCB). All pertinent Information on this study has been sub- mitted periodically to Darius Ostraskas of the Superfund Branch. For your Information, copies of pertinent correspondence and findings since early October 1984 are enclosed. Significant developments discussed 1n the enclosures include: 1. In late October 1984 the SWCB discovered several seeps In the bottom of the South Fork Shenandoah River adjacent to the Avtex Plant with above background levels of sulfate and specific conductivity. While the,elevated levels detected do hot contravene SWCB standards, they do Indicate hydraulic connection between the underground pollution and surface water. The results of the SWCB seep samplings are enclosed along with background transects* An earlier transect of the river by Avtex In June 1984 had not found any Indication of hydraulic connection between the subchannel pollution and the stream. The SWCBfltasl ftflyepted Avtex to analyze the river bottom seeps for all pertinent parameters'.HU i flRIOOOi*Q - i]> An Affirmative Aftinn/Kaital
Transcript
COMMONWEALTH of V1RQINIA
ORIGINAL(Red)
eonon STATE ER CONTROL BOARDExwutlw bimctor Vattey Regional Office BOARD MEMBERS
iJ6 North Main Street Patrick L-SundloflPost Offtet Box 11143 P.O. Box S68
. Virgin*228/2(703)828-2595
W»'wd B. Riei. 4r.- i , rtoc Witkliw M, Abbltt. Jr.4 January 1985 '/ '/ . Jowh8.c™g«^j
Robert C.WJninflerH»nry 0. Hollimon
Ms. Susan Insetta (3HW14)CERCLA EnforcementEnvironmental Protection Agency6th & Walnut StreetsPhiladelphia, PA 19106RE: Avtex Fibers, Inc., Front Royat, VADear Ms. Insetta: ;/ ;As recently discussed with you, Avtex Fibers, Inc., Front Royal, Virginiahas requested the Office of Emergency and Remedial Response to have theirHazardous Ranking System score revlied (see enclosures).As you are aware, Avtex Is conducting a comprehensive study of the groundwater pollution at this site at the request of the Virginia State WaterControl Board (SWCB). All pertinent Information on this study has been sub-mitted periodically to Darius Ostraskas of the Superfund Branch. For yourInformation, copies of pertinent correspondence and findings since earlyOctober 1984 are enclosed.Significant developments discussed 1n the enclosures include:
1. In late October 1984 the SWCB discovered several seeps In the bottomof the South Fork Shenandoah River adjacent to the Avtex Plant withabove background levels of sulfate and specific conductivity. Whilethe,elevated levels detected do hot contravene SWCB standards, theydo Indicate hydraulic connection between the underground pollutionand surface water. The results of the SWCB seep samplings are enclosedalong with background transects* An earlier transect of the river byAvtex In June 1984 had not found any Indication of hydraulic connectionbetween the subchannel pollution and the stream. The SWCBfltasl ftflyeptedAvtex to analyze the river bottom seeps for all pertinent parameters'.HU i
flRIOOOi*Q- i]>
An Affirmative Aftinn/Kaital
4 January 1985 -2- Ms. Susan InsettaORIGINAL
.•-.-.;..'<• tv * ; . ' . . - .-. "• . , ' * (Red)2. Avtex has drilled three new recovery wells and now has four wells
pumping contaminated water from the ground.3. The SWCB has requested Avtex to submit a comprehensive reclamation
plan for this pollution problem 1n early 1985*If you have any questions about the enclosures, please contact us. We willkeep you posted on new developments.
Sincerely, /
K. R. HinkleDirector of Special Projects
PlhEnclosurescc: Lauren F111more, Avtex
Richard Hughes, AvtexValley Forge, PA
i R. B. Chewnlng, SWCB
ORIGINALCOMMONWEALTH of VIRQINIA - (Ked)
STATE WATER CONTROL BOARD ,MktwtfN. Burton tOAHO MEMBER!
Pott Offkt Box 11143 AO. Bo* 268 OavM H. MiltarRichmond. Virginia 23230-1 143 BriJgevuttr, Virginia 2281 2 Vk»CtufrmM
(804) 297005* f j £28-2595Milled S.Rlct. Jr.
Watkint M. Abbltt, >.. . _ . , _ _ . " Jowph S. Cragw«II, Jr.13 December 1984 nobirtc.winma«r
RE: Ground Water Pollution StudyDear Ms. Fillmore: ,This letter sets forth some specific Items we would like to see addressed inyour upcoming Interim report and comprehensive program for reclamation ofthe contaminated ground water we discussed at our meeting of 7 November 1984and subsequently by telephone. Some Items should become a part of .the monthlystatus reports.The Interim report should Include a detailed discussion on the effectivenessof the recovery well program since It began In March 1984 and rationale forlocations of the recovery wells and any recommendations for additionalrecovery wells. Tables should be compiled showing operational times* downtime,rates, and total pumpage for each well* This Information should become a partof the regular monthly status reports as you submitted with the November reportbut In a tabulated form. ~.The reclamation proposal should Include a definitive plan and schedule forthe closing of Viscose Basins 9, 10, and 11 which have been Identified as theprimary source of the pollutants.The* recent findings from the stream survey conducted by the State Hater ControlBoard (SWCB) adjacent to the plant site should be addressed and compared withthe river study done by Avtex In June 1984. River sampling by Avtex since theSWCB survey should be addressed and recommendations made for additional studies.It may be necessary to Incorporate some stream sampling Into the reprogram.
An Afflrmativt Action/Equal Opportunity Employer
December 1984 -2- Ms. Lauren FWmore01f.W)
The matter of .apparent hydraulic connection with the river should now be fullyaddressed. Specifically, the consultant should address the Implications ofthe numerous fractures encountered In several of .the GM wells. Of particularconcern 1s the fact that air bubbles were seen 1n Sulfate Basin 4 and the riverwhen circulation was lost 1n GM-9 and the fact that a 1.5 ft. cavity was en-countered In GM-5. These conditions also need to be taken Into account Inarriving at conclusions on the lateral extent of the underground pollution.All quality and levels data collected from wells on both sides of the river todate should be discussed Including a comparison of .recent analyses from wellson the west side of .the river with the August 1983 analyses from these wells.This should also Inctade a discussion of the data generated since early 1982from the old shallow monitoring wells MW-1 through MW-8 with respect toconditions found In the deep GM wells,'ongoing recovery program, and extentof underground pollution.We have reviewed the monitoring well network proposal submitted with yourNovember report. While this Includes most of the key wells on the west bank ofthe river, we think there should be at least one additional well downstreamfrom these, say 178 or 179. Also, at this point we recommend sampling at aquarterly frequency for the first year to observe conditions more closely onthe west side of .the river. It may be necessary to periodically sample otherselected wells on the west side of the river and possibly make other modificationspending Initial results from the regular monitoring program. The interim reportshould Include the monitoring program with location map of wells.For those wells that are equipped with automatic recorders, the levels datafor the period of record should be summarized and addressed with respect toeffects of .the recovery well program. ^Land surface elevations are needed for all domestic wells on the west side ofthe river that have been Included 1n this study.The need for any additional wells on the west side of the river to delineate theextent of the underground pollution should be addressed, especially along thestrike of the most polluted zone southwest of well 177.We appreciate ygur continued cooperation 1n this matter. Please call 1f youhave any questions about the above.
• * • ' Sincerely, *
K. R. WnkleDirector of .Special Projects
plhcc: flark Wagoner, Geraghty & Miller A R | 0 0 0 k 3
R. Bradley Chewnlno,, SWCB"
MIRIAM Q. MATRANGOLASecretary
AVTEX FIBERS INC.P.O. BoxSSOValley Forge. PA 19482(215)251-7736
December 11, 1984VALLEY REGIONAL
Mr. Russell H. WyerDirector, Tiazardous Site Control Division (KPL Staff)Office of Emergency and Remedial Response (WH-548E)Environmental Protection Agency401 M Street, S.W.Washington, D.C. 20460
Dear Mr. Wyer: .
Subject: Comment* on proposed second update to the NationalPriorities Liat ("NPI.")Re.: Avtex Fibers Inc., Front Royal, Virginia Sit*
• _ _ _ ,__ .I, _ — _ v j
Enclosed is a ree valuation of the Hazardous Ranking System ("HRS")score for the Avtex Fiber* Inc. -Front Royal, Virginia site. It isour opinion that the amended HRS score more accurately reflectsgroundvater use and population distribution, than does the originalHRS score. We request that the Environmental Protection Agency re*vise its HRS score accordingly.
It is important to note that under the supervision of the VirginiaState Water Control Board ("SWCB") , Avtex Fiber* and consultantsGeraghty and Miller, groundvater geologist* and hydrologlsts, beganan investigation in March, 1983, to gather site specific informationconcerning the type and extent of groundvater contamination.
••*.The investigation was divided into several phase*. Phase I involvedthe evaluation of existing data on plant activities, disposal prac-tices and hydrogeologic condition*. Phase IIA consisted of resamplingof selected veils for key indicator parameter*. Phade IIB consistedof drilling and sampling to characterize the flow sy*tea and theextent of contamination. Phase IIB also identified the feasibilityof remedial measures.
AR10001*!*
••'••'
V : ••:_.;• 'OsiGiKAi.2
Mr. Russell E. Vyer December 11, 1984
Remedial measures have begun under the guidance of the Virginia SVCB.We are backpumplng the contaminated veil water from several veilsinto our vastevater treatment facility. To-datev we have treatedmore than six million gallons. In addition, Avtex Is in the processof developing a reclamation plan to be submitted to the Virginia SVCBin January, 1?85.
Sincerely yours,Is w- •• i _
~T*Miriam G. Katrangola
Ih
^^ Enclosures . -•
cc: R. Bradford Chewning, Virginia SWCB 'Lauren Fillmore, Avtex Fibers Inc., Front Royal, VirginiaRichard H. Hughes, Avtex fibers Inc., Valley Forge, PA
fiRIOOOl+5
AVTEX FIBERS INC, Box 1169, Kendrick Lane, Front Royal, VA 22630 (703) 635-2141
Decanter 5, 1984
Mr. Nllllam PolandP. 0. Box 1124Front Royal, VA 22630Dear Mr. Poland:Enclosed 1s a copy of the analyses run on yourgroundwater sampled from your yard spigot onSeptember 26, 1984.
* Sulfate as S 193 stg/L** Total Recoverable Phenolic* 1.47 mg/L" C.O.D. < 20 mg/L" , Lead, total O.OC8 mg/L* "•'••'. : .V, Cadmium, total < 0.002 mg/L
i . " ..--•>-. Sodium, total 8.6 mg/LS " Zinc, total :>, < 0.05 mg/L
jArsenlc, total < 0.04 mg/Ltron, total 1.16 mg/LCopper, total < 0.10 mg/L
\°
ftR I 0001*7
AVTEX FIBERS INC. Box 1169. Kendrick Lane. Front Royal. VA 22630 (703) 635-2141
December 6, 1984
Mr. William KregloePollution Control EngineerState Water Control BoardValley Regional OfficeP. O. Box 268Bridgewater, VA 22812
Dear Mr. Kregloe:
Effective January 1* 1985, Mr. C. Ray Enicks will be Plant Manager atAvtex Fibers, Front Royal plant, NPDES Permit No. VA 0002208.
After that date, Mr. Enicks will be the principal executive officer andwill sign the monthly Discharge Monitoring Reports.
Sincerely,
Eldon E. CampbellVICE-PRESIDENTRAYON OPERATIONS
EEC/mjh
CCi Mr. Brad Chewning-SUCBMr. C. R. Enicks
OOOl;8
• \
AVTEX FIBERS INC. Box 1169, Kendrick Lane. Front Royal, VA 22630 (703) 635-2141
December 6, 1984
Mr. Ken HinkleDirector of Special ProjectsState Water Control BoardValley Regional OfficeP. O. Box 268Bridgewater, VA 22812
Dear Kr. Hinkle:
REl GROUNDWATER STUDY * PROGRESS REPORT, NOVEMBER, 1984
All three of the veils proposed in June have been installed and Geraghty andKiller's geologists have performed pump tests on the new veils. Based uponinformation obtained from these tests, Geraghty and Killer have recommendedthat PW-3 be placed on the air lift pump system used for PW-1 and PW-2.PW-0 has very little flow and a pump jack was recommended to be installed.Currently, there is a level recorder in PW-0.
Except for four hours when the compressor was turned off for winterization,PW-2 has been pumping constantly since November 8. An estimated 0.6 milliongallons have been removed during November. PW-3 has been pumping continuouslyfrom November 17. An estimated 0.37 million gallons have been removed. PWrlwas started in mid-November, however, due to problems with line blockages, itwas out of service frequently during that time. A new line installed fromPW-1 on November 26 corrected the problem. An estimated 0.09 million gallonswas pumped from this well during November. ~»
The additional groundwater analyses agreed upon in our November 7 meeting isbeing scheduled for the second week of January.
»Geraghty and Miller wishes to perform a recovery test In order to answer someof the questions raised at the November meeting. This Beans that the wells willnot be pumping for four to five days while the groundwater recovery is measuredby 20 level recorders placed on select monitoring and west bank wells.Information obtained from this test will determine the area ofjthe recovery system. This test will also occur during the second? veJanuary.
AR I 0001;9
Mr. Ken Hinkle -2- December 6, 1984
• • - - •.. '"-I"Enclosed is a proposal for additional monitoring plus a listing of all ^laboratories used by Avtex and Geraghty £ Miller since the start of the ?groundwater monitoring in 1982.
LABORATORIES USED BY AVTEX FIBERS FORIKtriLIATPP CAMP I TMft • .
MLJCJ-uauJ VALLEY REGIONAL. OFFICS
1. Viroinia Polytechnic February 1982 - A*,Cd,Pb,S»Infttltutt & St*t* Univ. April 1982.Ctnttr for Environ. StudiesBUcksburg. V» 240*1 ?-^ --- ! ' - v r - i -
2. Commonwtitlth L*b», Inc . F«bru*ry 1982 - TOC.Ni tr*tt«,CS22209 E. Broad Strttt March 1983 Total phtnoU.Richmond, V* €3223 :" c" : Alk*1inl ty,Sulf id**,
3. Mtasurtmtnt Scitnct* Co. August 1983 TDS. Conductance ,TOC,300 6*rd«n City PUz* TOX.EPA 601, AcidGarden City. N.Y. 11530 Extractabl ts.
4. Biospheric* Inc. April 1983 TOC.A1 k*l in i ty,CS2,4928 Uyaconda Road September 1983 Sulf idet.Chlor ides.Rockville, Md 20852 Sul-fate*.TOX,OMNA,
*- T0**1 phenol *,Cd.1 >''•< l Pb,EPA 601, Acid
Extractables.
5. Awtex Fiber* February 1982 - CS2."Hardne**.TDS.TSS.Compl iance Laboratory April 1984 Chlor ide.Sul-fate.COD,Front Royal , Va 22630 *r . - Al kal i n i ty.Sul f i de,- - . ' • ' . '• • • • • - - • : " - - . i;- : r -- '•• , ' Zn,Na,Fe,Mn.
• ; ,;?|--r* •- . . • • .
February 1982 - pH, Conductance .Present Level readings.
6. Environmental Labs December 1983 - TOC. Alkali n i ty»CS2,103 S. Leadbetter Road Present Sulf ides,SuHate.TOX,Ashland, Ua 23005 Chlor f de.-COD.TSS.TDS.
Total phenol stCd,Pb.As,Na,Zn,GC/MS ldent.vpeaks.
AR10005 I
/***»•;* •*\ '.1 li."
1. Semi-annual monitor)no o-f west bank wells
Sampli np Month * Apr 11« Octobtr
WtlU to bt sampltd - GM6 or PW2, GM2A, Youno <J77>.Schilling (181). Smith (137). Frum, Lonotrb*am (141).
Wtathtrholtz Property purchased NAby Avtex. Dwell Innremoved.
PROPERTY OUNERi RESIDENT STATUS x WATER STATUS I» • . .
Walter Crump* Property purchased NAby Avtex. Dwelling • • ,<M>-Mvacant. !»ir,AL
*d)Russell Brown Property purch**td NA
An It* Lumkey Property purchnsed NAby Autex.
J*ck Uinter«t«en No dwell Ing. NA
Clifton Johnson No dwelling. NA
C*rl Cookerly . Property purchased NAby Auttx.
•Full time resident* in 1980. The number o-f lndiuidue.ltrelocated *re as followsi Smith <2>f Naqi (2); Schilling <2)iRitter <4> t Longer be *m (2)t Rjitlif-f <1)| Cornett (4) |Crump <2> .
Dear Hs. Bergeson: ;. . •-*As requested 1n your October 30, 1984 letter, we are transmitting copies of ourfile relative to the ground water contamination problem 1n Front Royal. Thisdata covers the period after June 15 to the present. '
The costs for the 21 pages copied for you amount to $2.10 plus 886 for postage.The charge for photocopies represents the standard copying charge of loi/page.By copy of this letter, the Board's Accounting Office In Richmond is notifiedof these charges and will A111 you for this amount. Upon receipt of theBoard's invoice, please make your check for $2.98 payable to the VirginiaState Water -Control Board and Indicate .the reason for payment on your check.
: ; - . -<.; '•> »- " j ...; -.'•-.. , • • ' • ' " - "If you need further information, please let us know.
Ri BradleysSKewning, P.ERegional Director
"
^Enclosure. :
cc: Finance ' • - - -VRO File
, ... , : P^ u AR 10005-6\* */ . - . •«,. • - - • " •
An Affirmative Action/Egual Opportunity Employer
AVTBX FIBERS ViC. Box 1169, KendrickUne, Front Royal VA22630 (703) 635 141
November 12. 1984 f l . ,
Mr. Ken HinkleDirector of Special Project* -, • VALtfy Rm-tASTATE WATER CONTROL BOARD OF S;***2Valley Regional Office ™ •_.;,;;P. 0. Box 268 t\-Bridgewater, Virginia 22812 ''"
Dear Mr. Hinkle!
REi ADDITIONAL GROUNDUATER ANALYSIS
During our meeting on November 7, 1984, Avtex agreed to sampleadditional west bank wells south of GM2A and B. These wells w i l lbe Frum, George Martin (185), and Ritter <92>, which is locatedwest on the ridoe. Young (177), Schilling <181), and GM2A wellsw i l l be resampled, since the pump systems on our west dike w i l lbe operational during this sampling period. Tentatively, thissampling will occur during the last week of November or in earlyDecember. - • •
Ule w i l l also sample the three new wells drilled on our west dike,PU8, PUJ3, and PU4. GM6, located fttxt to PU2 w i l l also beresampled. The parameters to be analyztd will be the same onesthat we do during our quarterly groundwater sampling.
VPI's Center for Environmental Studies w i l l be conducting abenthic survey through the area where the seeps were identified.At this time, I wil l also be sampling some (18) of these seepsfor the same chemical parameters that we report for our quarterlygroundwater sampling program. I will let you know the exact datefor the scheduled sampling so that arrangements can be made forone of your surveillance team to be present to split samples aswe discussed on November 9.
Attached is an updated site map with the locations of the new PUwells. If you have any questions* please call.
Si-ncer^ely,.ARIOQ057
>vtLauren Fi1ImoreTechn i c'al Super i ntendent.ENVIRONMENT
LF/mjh - •
Locations of Monitor and Pumping Wells
November ,2.;t934 flfi,00058
Corrected Copy
J Jf
VAVTCX FIBERS INC. Box 1169. Kendrick Lane, Front Royal, VA 22630 (703) 635-2141
October 31, 1984
Mr. Ken HlnkleDirector of Special ProjectsState Water Control BoardValley Regional OfficeP. 0. Box 268Brldgewater, VA 22812Dear Mr. Hlnkle:RE: GROUNDWATER STUDY - PROGRESS REPORT, OCTOBER, 1984
Wells PW-1 and PW-2 have been refurbished by Geraghty and Miller.The new materials are on site for the Installation of the pumpsystem. The system should be Installed and operational byNovember 2.~Geraghty and Miller have completely Installed one of the threeproposed wells. This well, PW-0, 1s located south of PW-1.PU-3, located north of PW-2, has been started. After theInstallation of the three wells, Geraghty and Miller will performpump tests on these wells.On October 22 and 23, Geraghty and Miller resampled selected westbank wells, GM2A, GM2B, 178, 181, 141, 177. and 179. PW-1 and PW-2on Avtex's site were also sampled. The data will be forwarded whenavailable. ~*
Ms. Lauren Flllmbre v ! -Technical Superintendent, Environment ,Avtex Fibers, Inc.P.O. Box 1169, Kendrick LaneFront Royal, Virginia 22630 < -^ ,Re: Ground Water Pollution Study ''l0''*/
' ffecf?Dear Ms. Fillmore:Avtex has been asked to resolve the ground water pollution problem and attainthe objectives as presented to the Company in January 1983. Part of the objec-tives have been achieved, i.e., alleviating the problem of unsafe water for thedomestic well users across the river and Identifying a primary source of theground water pollution. However, we believe much work is still to be done indetermining the extent of the underground pollution end Implementing « reclama-tion program. : •
Specifically, we want from you a comprehensive program of reclamation for thecontaminated ground water. We believe you are at the point that you can provideus with such a program. Your submlttal should Include specific actions and datesto complete those actions. The;comments and questions listed below should assistyou 1n the development of that program. Further, we believe the development ofsuch a program can be done In a short period of time. We are ready to discusswith you a date of submlttal for thiscomprehensive reclamation program.
1. The sharp reduction in chemical concentrations In well PW-2 **between January and June 1984 is encouraging. However, weare interested In seeing some current analyses for key param-eters from the severely-contaminated wells on the west bankof the river. This 1s vital Information to determine theeffectiveness of the recovery well program. When can weexpect to see some analyses from these wells?
2. We understand that three new wells are to be drilled on theAvtex side of the river in the next few weeks. When 4p?s .the ...Company expect to Have t full scale recovery well progoperation that will remove the underground pollutants?
3. We are very much interested 1n seeing a firm schedule foremptying end closure cf the three viscose basins $f$ |h@/9 062
An Affirmative Action/Eoual OoDortunitv Emolovmr
&&$&'" ".1P^ •18 October 1984 -2- Ms. Lauren Flllmore
«
been identified as the primary source of the ground waterpollution. Any secondary sources should also be addressed.
• ' " - ' " . . . ' * *
4. The Interim report proposed by the consultant should give acomprehensive assessment of what has been learned to date and» definite plan and schedule of cleanup and elimination of theground water pollution.
5. As for determining extent of the ground water pollution,fracture trace analyses may be helpful in mapping possibleconduits for migration of pollutants. We do not fullyunderstand the significance -of using Infrared photographyto answer that question. The depth to ground water seems topreclude the use of infrared photography for that purpose.Ftzrthes studies of the existing domestic wells and Installedmonitoring wells should help to answer this question. Someadditional test wells may also be necessary on the west side fRccof the river.
With regard to Avtex being recently placed on the proposed Superfund 11st byEPA, we do not know at this time what would be required by EPA. In any event,the State Water Control Board expects Avtex to continue its efforts to solvethis problem as set forth above.The results of the river transects conducted 1n June 1984 do not Indicate anyconnection between the polluted ground water beneath the river and the riveritself. We see no need for further river studies at this time.We can discuss these matters at our upcoming meeting on the 7th of November.Please call 1f you have any questions.
-"ft* • ,
Sincerely,
K. R. HlnkleDirector of Special Projects
KRHiOccc: Jeanie Grandstaff» Office of Enforcement
R. Bradley Chewnlng, W. L. Kregloe - VROJeff Sgambat, Geraghty and Miller, Inc.
